FFIEC BSA/AML Examination Manual

Appendix H: Request Letter Items (Core and Expanded)

• Provide the code of ethics for foreign branches or offices, if it is different from the bank’s standard policy. • When testing is performed, provide a list of accounts originated or serviced in the foreign branch or office. Examiners should try to limit this request and focus on accounts for specific products or services, higher-risk accounts only, or accounts for which exceptions or audit concerns have been noted. • Provide a list of the locations of foreign branches and offices, including, if possible, the host country regulatory agency and contact information. • Provide the organizational structure of the foreign branches and offices, including reporting lines to the U.S. bank level. Parallel Banking • Provide a list of any parallel banking relationships. • Make available copies of policies, procedures, and processes specifically for parallel banking relationships, including procedures relating to higher-risk money laundering activities. Such policies and procedures should include those that are specific to the relationship with the parallel entity. • Provide a list SARs filed relating to parallel banking relationships. • Make available documents that specify limits or procedures that should be followed when dealing with the parallel entity. • Provide a list of directors or officers of the bank who are also associated with the foreign parallel bank. Electronic Banking • Make available copies of any policies and procedures related directly to electronic banking (e-banking) that are not already included in the BSA/AML policies. • Provide management reports that indicate the monthly volume of e-banking activity. • Provide a list of business customers regularly conducting e-banking transactions, including the number and dollar volume of transactions. • Make available a list of service providers related to Remote Deposit Capture (RDC) activities. • Make available copies of contracts related to RDC activities. Funds Transfers • Provide funds transfer activity logs, including funds transfers that involve cover payments, including transfers into and out of the bank. Include the number and dollar volume of funds transfer activity for the month. • Provide a list of funds transfers purchased with currency over a specified time period.

FFIEC BSA/AML Examination Manual

H–9

2/27/2015.V2